International Raw Materials Observatory, AISBL
INTRAW
The International Raw Materials Observatory is an international not-for-profit international association, established on 25 September 2017.
ID: 367580436203-11
Lobbying Activity
Meeting with Radan Kanev (Member of the European Parliament)
13 Oct 2025 · Critical Raw Materials Act Implementation
Meeting with Hildegard Bentele (Member of the European Parliament)
13 Oct 2025 · Raw Materials
Response to European Critical Raw Materials Act
22 Nov 2022
The International Raw Materials Observatory (INTRAW) supports the Commissions initiative and wishes to make the following observations and recommendations under the following headings: 1. Policy and Strategy. 2. Governance. 3. Permitting. 4. Substantive Support. 5. Research and Innovation. 1. Policy and Strategy The criticality of certain raw materials is a direct function of the envisaged socio-economic trajectory as well as short-term and long-term geopolitical developments. However, the current criteria for why certain raw materials are considered 'critical' are not very clear and appear to be rather static. In order to address the mineral precarity over the various time-scale we need: Development socio-economic trajectory-based criticality assessment Foresight studies Factorisation of criticality Systemic approaches Realistic recycling scenarios Societal metabolism conundrums to be resolved Resilience through diversification 2. Governance Western World citizens have become increasingly detached from and unaware of the production side in the nexus food-water-energy-raw materials. This has resulted in extraction taking place overseas and, therefore, the displacement of the associated externalities to other, potentially more vulnerable societies, while Europeans claim to have protected their environment and a healthy style of living. To address this ethical and economic paradox, the EU needs to: Look not only into the environmental and societal impacts from domestic mineral extraction, but also into the environmental and societal impacts from not having EU domestic extraction. Be aware that not having EU domestic extraction also means that the EU foregoes the economic opportunities associated with having as much of the value-webs within the EU jurisdiction as possible. Increase educational and information efforts to raise the awareness of the risks and socio-economic implications inherent to current mineral raw materials value-webs. 3. Permitting Slow, intransparent, uncertain, and sectoral permitting procedures have been identified as a key obstacle to attracting investment into exploration and extraction as a basis for re-domiciliation of mineral raw materials value-web to the EU. Therefore, the EU needs to: Initiate a societal discourse that recognises the importance of balancing societal needs and interests. Raise the awareness among land-use planners, regulators and political decision-makers of the need to provide access to mineral raw materials within the EU with a view to increase the EU supply resilience. Enable permitting authorities to perform the task of responsibly licensing extractive operations while balancing the wide variety of socio-economic needs, societal expectations and objective sustainability and biodiversity needs. 4. Substantive Support Resiliency support - Short-term solutions could include developing joint material reserves or creating barter and resource-sharing mechanisms. Active diversification of supply-webs will increase the EU resilience. Empowering suppliers - The EU Commission may want to help to create a more level playing-field by helping potential resource partner countries, developing their regulatory and governance framework. Rebuilding human resources in the mineral raw materials value-webs is a necessary condition for competent domestic value-webs.. 5. Research and Innovation Continued strategic support - Financial and institutional incentives, e.g., through a sustained funding of raw materials-related for research & development clusters to thrive and with its innovative solutions support the overseas-to-domestic resourcing transition along the whole life-cycle of materials, from exploration to recycling and residual waste management. Continued support for ERA-MIN funded multilateral R&I projects involving also associated countries.
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